Russia-related General License 30A - Authorizing Transactions Involving SEFE Securing Energy for Europe GmbH Prohibited by Directive 3 under Executive Order 14024 (July 14, 2022) [PDF includes all versions]

Date issued: Jul. 14 2022

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TURBOFAC Commentary (215 words)

Notes:

1) This GL is, this far, the only GL that aimed at authorizing transactions otherwise prohibited by Directive 3 Under EO 14024, but other GLs (e.g. Russia-related General License 6) implicitly license against Directive 3 Under EO 14024.

2) See "Berlin seizes control of Gazprom Germania" (Financial Times - April 4, 2022 - (https://www.ft.com/content/85d0d9b2-ae8a-4889-9133-96d628ad25e5)). Gazprom Germania GmbH is not on the SDN list. It is therefore evident that OFAC does not regard the unilateral German government actions vis-a-vis Gazprom to have had the effect of releasing Gazprom Germania GmbH from sanctions resulting from application of the 50% rule. The article says "In a statement [], economy minister Robert Habeck said the Bundesnetzagentur, Germany’s federal energy regulator, would become temporary trustee of...